1.    Overview PATE PLAY LTD. places the securing of privacy in the first place when dealing with the personal data of its website visitors, job applicants and existing and potential contractual partners. We are committed to ensure that your personal data is consistently and effectively processed and protected. 

‍PATE PLAY LTD., UIC205971839, with seat and management address inBulgaria, Sofia 1784, Mladost district, 159 Tsarigradsko Shose Blvd.,e-mail: dpo@pateplay.com (hereinafter referred to as the “Pate Play” or the “Company”) is a data controller and as such it complies with the rules and requirements of theBulgarian and European legislation on personal data protection, including the PersonalData Protection Act and the General Data Protection Regulation (“GDPR”)( Regulation(EU) 2016/679)). 

The purpose of this PrivacyPolicy is to explain how Pate Play processes the personal data related to the persons (data subjects) specified below, for what purposes Pate Play collects and processes their personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by Pate Play. 

With respect to the processing of personal data relating to job applicants with us, this PrivacyPolicy is applicable in addition to the Privacy Notice for Job Applicants available below. 

‍2.    What types of personal data do we collect and why?
‘Personal data’ is defined as any information relating to an identified or identifiable natural person (‘data subject’) /Article4 (1) GDPR/. It can include identifiers like your name but also identification numbers, location data, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
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‍‘Special categories of personal data‘ include information about racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation /Article 9, para. 1 GDPR/. 
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Pate Play processes various types of personal data necessary for:- the lawful and normal conduct of the Company’s business; - the conclusion and execution of various contracts between the Company and third parties;
- the provision of services to the Company by suppliers;
- for the fulfillment of obligations established by a legal obligation;
- communication and provision of information and documents to the national and foreign public and regulatory bodies;
- as well as for other legal purposes related to the business activities carried out by the Company. 

3.    Which are the persons (data subjects) whose personal data is processed?
‍We process personal data related to the following persons (“You”):
-   Visitors of our Website - www.pateplay.com and users of its information resources;
-   Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;
-   Applicants for employment at Pate Play;
-  Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners (“Contractors“), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners.
- With technical means for video surveillance, we process personal data of data subjects who visit, pass through, or otherwise are in the designated video surveillance zones in the offices of the Company. 

‍A. Website visitors Every time you visit our website, we collect access data that is sent to us automatically by your browser. This facilitates your use of the website. The access information includes, in particular: IP address of the requesting device; date and time of the request; address of the requesting and requested website; information about the browser and operating system used; online identification data (e.g.device ID, session ID). The processing of this data is necessary to enable you to visit the website and to guarantee the functionality and security of our systems. However, this data is measured only in aggregate and not on an individual basis. For more information, please see our Cookie Policy. When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details /e-mail address and other information included in the e-mail/, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry. 
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‍B. ContractorsThe personal data that may be collected and processed by Pate Play within our relations withContractors might be the following:
-   Identification data of Contractors, their legal representatives and proxies – name, PersonalIdentification Number (PIN) or another identification number/code, date of birth, citizenship, ID card, and/or passport details, as well as identification data about the ultimate beneficial owners and representatives of the companies with which we are to enter into contractual relations;
-       Business contact details – address, contact phone, e-mail;
-       Other personal data that may be provided by our business contacts when filling out client/partner questionnaires;
-    Other information related to the Contractors, their employees and representatives, provided or created in the context of our business relations and activities, including in negotiations and legal disputes. The processing of personal data about the above mentioned data subjects is necessary for PatePlay for the conclusion, execution, and/or termination of contracts; identification of beneficial owners of legal entities – our suppliers and business partners, in view of our internal policies and rules. Without processing of the said personal data, Pate Play cannot enter in to contracts with its Contractors or fulfill its obligations under them. 

C. Video surveillance Pate Play provides video surveillance in the common areas and entrances to the offices of the Company. The video surveillance is carried out for the purpose of self-protection of the Company’s property, and protection of the life and health of our employees and visitors. 

4.    For what purposes do Pate Play process your personal data? 
Pate Play processes personal data for the following purposes: 

A. Processing of personal data on grounds of provided consent of the data subject
‍-       Personal data provided with your explicit consent for a specific purpose (when applicable). 

B. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors
‍-       Identification of legal representatives, proxies, employees, and beneficial owners through publicly available channels, as well as when these data are provided by theContractors of Pate Play before the conclusion of the contract;
-       Preparation of offers, contracts, and all other documents accompanying the contract, as well as any other documents created in the context of business relations with the business partners of the Company;
-       Notices related to our products and services. 

C. Processing of personal data needed for compliance with a legal obligation
‍-       Personal data necessary for compliance with a legal obligation of Pate Play, including, but not limited to, legal obligations established in the tax and accounting legislation; gambling legislation; customs legislation, etc. 

D. Processing of personal data based on legitimate interest
‍-       Video surveillance in our administrative sites;
-       Provision of data by you in our client/partner questionnaires, such as data about politically exposed persons;
-       Verification of the existence of licenses, permits, concessions, and/or other rights related to the exercise of regulated activities by our business partners;
-       Exercising and protecting the legal rights and interests of the Company.  
‍Your personal data is processed following the principles of: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; accountability. 

5.    То whom may Pate Play disclose your personal data?
Pate Play may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. Pate Play does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met. Recipients of personal data may be third-party legal and individuals, such as:
-       service providers and their subcontractors;
-       postal and courier service providers;
-       external consultants in various fields providing services to the Company, such as, but not limited to, banks, financial auditors, legal advisers, advertising agencies, security companies, and other service providers;
-       service providers which on assignment and on behalf of the Company maintain equipment, software, and hardware used to support the activities of Pate Play, as well as hosting companies and sales agents, etc.;
-       state and municipal bodies, including, but not limited to, regulatory bodies, state commissions, institutions and agencies, NRA, NSSI, courts, prosecutor’s office, and others, to which Pate Play should provide information that may contain personal data under the applicable legislation. 

6.    What technical and organizational measures for data protection do we apply?
‍In accordance with applicable law, PatePlay implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.In addition, Pate Play implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.

7.    How long do we retain your personal data?
Pate Play stores personal data up to 12 months after the statutory time limits for storage or 12 months after the purpose for processing of the personal data ceases to exist. The Company deletes personal data after the expiration of this period.

8.    Do we transfer personal data outside EU/EEA?
‍The transfer of personal data is secured by modern technical means. In principle, Pate Play does not transfer personal data to persons outside the EU / EEA. In the event that such transfer is necessary for the fulfillment of some of the above purposes, the transfer will be carried out in compliance with the requirements of applicable law.

9.    What are your rights in relation to the protection of your personal data?
‍In order to fulfill the obligations of PatePlay as a data controller, it is important for the Company to process and maintain your personal data accurate and up-to-date; if necessary, you may request an update of your personal data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on personal data protection.

You have certain rights related to the processing of your personal data provided in the GDPR, including:

a.     Right to obtain confirmation from Pate Play that your personal data is being processed and, where that is the case, access to your personal data, as well as the right to request a copy of your personal data stored or otherwise processed by Pate Play;

b.     The right to request rectification(correction) of your personal data in case it is inaccurate, no tup-to-date, or incomplete;

c.      In the presence of the conditions set out in the GDPR or national law, you also have the right to request the erasure of your personal data (‘right to be forgotten’) or the restriction of their processing, as well as to exercise your right to the portability of your personal data (when applicable);

d.     Right to object, as well as rights related to automated decision-making – you have the right to object at any time, on grounds relating to your specific situation against the processing of your personal data, including in the event that your personal data is used for profiling;

e.     If you have any doubts that your personal data is not being processed lawfully by Pate Play, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Notice, or to seek the protection of your rights judicially.

f.      Please note that Pate Play does not use your personal data for profiling or automated decision making.

The terms and conditions for exercising your rights related to the protection of personal data are regulated in detail in the GDPR and the Bulgarian Personal Data Protection Act. You may exercise your rights by making a written request to Pate Play on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Pate Play will provide you with full assistance in exercising the rights granted to you.

‍Data Protection Officer 
‍If you wish to receive additional information on how Pate Play processes your personal data or you have questions related to the operation and application of the present Transparency Notice in the processing of personal data of employment applicants, you can contact thePersonal Data Protection Officer, at the following e-mail address: dpo@pateplay.com.
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‍Competent national supervisory authority for Personal Data Protection
Commission for Personal DataProtection
‍Address: 2 Professor Tsvetan Lazarov Blvd., Sofia 1592
E-mail: kzld@cpdp.bgWebsite: www.cpdp.bg 

‍Changes to the present Personal    
Data Protection PolicyThis DataProtection Policy may be amended over time, and the changes made to it shallbecome effective promptly after being announced on the Company’s website.

‍This Notice is effective as of 01.09.2023.
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PRIVACY NOTICE FOR JOB APPLICANTS AT PATEPLAY LTD.
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1. About the Privacy Notice for Job Applicants
‍1.1. PATE PLAY LTD., UnifiedIdentification Code 205971839, with seat and registered address at in Bulgaria, Sofia 1784, Mladost district, 159 Tsarigradsko Shose Blvd, e-mail: dpo@pateplay.com (hereinafter referred to as the “Pate Play” or the “Company”) is a data controller and as a data controller it complies with the rules and requirements of the Bulgarian and European legislation on personal data protection.

1.2. The present PrivacyNotice for Job Applicants at Pate Play (hereinafter also referred to as the “Privacy Notice” or just the “Notice”) aims to provide information on the processing of personal data of individuals (or also “data subjects”) who have voluntarily and on their initiative submitted their job application, CV and contacts by using:  - the form on the website www.pateplay.com; - the designated for recruitment purposes e-mail address recruitment@pateplay.com; or - in any other way that may be used by Pate Play for recruitment and selection purposes, e.g. through another electronic address, through a job posting platform maintained by a third-party, etc. 

1.3. This Privacy Notice applies also to personal data provided by applicants for employment at Pate Play by sending their application in hard copy to the physical address for correspondence with the Company.

1.4. In the capacity of individuals –applicants for employment, whether you are applying for a specific vacancy advertised by Pate Play  or you are submitting your application without the Company having advertised a current vacancy, you have the right to be informed about how and why Pate Play, as a data controller, collects, processes, stores and protects your personal data which you have provided to the Company in connection with your job application.

1.5. Please, read this Notice carefully to understand how we process your personal data in the context of recruitment and selection and what your rights are in relation to this processing. By submitting your job application electronically and clicking on the button provided for this purpose, you declare and state that you have read the terms of this Privacy Notice. In case you need any additional information or have any questions regarding the processing of your personal data in the recruitment and selection process, you may contact PatePlay at the contacts listed below in the Notice.

1.6. The present Notice does not restrict your rights related to the processing of your personal data by PatePlay in any way. The purpose of this Notice is to provide you with information that shall ensure the transparent and fair processing of your personal data by Pate Play in the recruitment and selection process. 

‍2. What types of information do we collect when you submit your job application to us and why?
‍2.1. Pate Play processes the personal data provided by you in its capacity as a data controller. TheCompany collects and processes only those categories of personal data that have been provided to the Company voluntarily and directly by the applicants, or such personal data that were additionally provided by the applicants during the recruitment procedure and/or requested by Pate Play within the procedure for evaluating your application and the decision-making process on whether recruit you.

2.2. In certain cases, the personal data processed by Pate Play in connection with your application is not collected or received directly from you, but from third parties such as recruitment agencies – e.g. when you apply through such agencies.

2.3. PatePlay processes the following categories of personal data related to your job application, which you have provided voluntarily as part of your application and recruitment process:
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‍Identification data about you (name, contact details – address (current and/or permanent address), telephone number, e-mail address), date of birth, photograph (as long as they are provided voluntarily by you as part of your job application);
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‍Information on education and acquired professional qualifications – completed education, acquired professional qualifications, scientific degree; completed educational courses, trainings, seminars, and/or other information related to acquired education and qualifications; knowledge of foreign languages and previous professional experience, as well as other information related to your skills and qualifications;
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‍Information on current and/or previous employment – details of employment; work experience; posts/positions held; roles and responsibilities performed;     current and/or previous employers; length of service/experience; references and references from employer(s) where these have been volunteered by you; Information concerning the possession of a driving license or other certificates of acquired competence (where and to the extent that such competence is necessary and required for the performance of the duties included in the scope of the position for which you are applying or when you have voluntarily provided such information);
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‍Information on remuneration, including expected remuneration for the position you are applying for, additional social benefits, and/or other data of a financial and economic nature     related to the position you are applying for; Information     that you have voluntarily provided on your initiative in the process of     your job application and that is not included in the above (e.g.     information provided through a CV, cover letter, and/or another document     that you have provided or has been additionally requested from Pate     Play within the recruitment procedure); Information     collected and prepared by recruitment agencies and employment     intermediaries to whom Pate Play has assigned recruitment     activities, including collecting, reviewing, and evaluating applications,     conducting interviews, and preparing reports and     recommendations; Other information relating to     your application that you have provided voluntarily during the recruitment     process.

2.4. Pate Play does not process special categories (“sensitive“) of personal data as part of the recruitment process. By way of exception, such categories of personal data could be processed only and insofar as they are necessary for the assessment of your application in view of the particularities of the specific job position and the decision to appoint you to a specific job/position, as well as for the fulfillment of certain statutory obligations which shall be observed by Pate Play in its capacity as an employer, or if there is another reason for processing this category of personal data, with your explicit consent for their processing. 

‍3. For what purposes does Pate Play process your personal data?
‍3.1. As a potential employer, within the recruitment and selection procedure, Pate Play processes your personal data only insofar as it is necessary for the Company to conduct the procedure for selection of potential employees, evaluation of your application, taking a decision on your appointment as an employee of the Company, preparation of a proposal for starting work (offer) and/or preparation of a draft employment contract. In particular, Pate Play processes the personal data you provide for the following purposes:

Administration  and management of your job application in Pate Play, including identification, written and oral communication with job applicants during     the selection procedure;

Carrying out a selection and evaluation of your application and deciding whether to make you an offer of an employment contract;

Upon approval of your application, for the preparation of a formal job offer, preparation of a draft employment contract, and other documents necessary to complete the process of appointing you to the position for which you are applying;

In case you have not been offered an employment contract or it has not been accepted, Pate Play may process the personal data of your application for other current or future vacancies, provided that you have given us your explicit written consent that your application can be considered for this purpose.

3.2. Pate Play may process your personal data in the presence of at least one of the following legal grounds, laid down in the General Data Protection Regulation (“GDPR“):
In the presence of your consent to the processing of your personal data;

To take the necessary actions to enter into a contract (employment contract) if your application is successful and you have  accepted our offer of employment with Pate Play;

Existence  of a legitimate interest of Pate Play, as our legitimate interest is to assess the compliance of your application with the needs of the Company, the necessary requirements for the position, and to recruit personnel in order to fill our vacancies;

In order to comply with a legal obligation that applies to us under the GDPR, such as the obligation to respond to your inquiry relating to the protection of your personal data that we process or in order to protect our legitimate interests.

‍4. When do we delete your personal data, provided within the procedure for selection and evaluation of your application?
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‍4.1. Pate Play will store and process your personal data only for the period necessary to achieve the purposes of personal data processing set out above. In particular, your personal data will be stored for the period from their receipt until the final decision on whether to be appointed to the position for which you are applying, but for no more than 6 (six) months after the completion of the selection procedure, unless the applicant has given his/her explicit consent to store them for a longer period of time.

4.2. Please note that the retention period of your personal data provided in the process of your application may exceed the expiration date of the advertisement published by Pate Play for the position you are applying for. This is because after receiving the applications of the interested candidates, technological time is needed to carry out additional actions such as internal evaluation of the received applications, conducting interviews with the candidates, discussing and making a decision by Pate Play to choose the most suitable candidate and concluding a contract with him.

4.3. For the purpose of occupying other current or future vacancies, it is possible that Pate Play will store your personal data even after the completion of the procedure for occupying the position for which you are specifically applying. In this case, Pate Play will store your personal data for a period not exceeding 1 (one) year, provided that you have given us your explicit written consent for this purpose. You can withdraw your consent at any time by notifying Pate Play. 

4.4. In case your application is approved, when concluding an employment contract between you and Pate Play, the personal data provided by you (or part of them, as the case may be) will continue to be processed by Pate Play and will become part of your employment dossier, which the employer is obliged to compile and maintain. Incase you are selected for a relevant position, to conclude the employment contract it may be necessary to provide additional information and documents, in accordance with the requirements of applicable law and the internal rules and procedures of Pate Play.

‍4.5. When concluding an employment contract, Pate Play will provide you with a detailed privacy notice regarding the processing of your personal data in your capacity as an employee of the Company.

4.6. In case your application is not approved and you have not given your consent to Pate Play to store and process your personal data for other current or future vacancies, your personal data will be destroyed and/or deleted (depending on the media) after the completion of the selection procedure for the relevant position for which you have applied, but no later than 6 (six) months after that.

‍5. To whom may we disclose your personal data provided in the framework of the recruitment procedure?
‍As part of the recruitment procedure, the personal data which you provided will not be disclosed by Pate Play to third parties. Your personal data will be brought to knowledge (disclosed)only to employees of the relevant departments of Pate Play, determined according to the specific position you are applying for, to participate in the process of managing and administering your application, who are directly involved in the process of selection, analysis and evaluation of your application for the position.

‍6. What are Your rights in relation to the protection of your personal data?
‍6.1. In order to fulfill the obligations of Pate Play as a Data Controller, it is important for the Company to process and maintain your personal data accurate and up-to-date; if necessary, you may request an update of your personal data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on personal data protection.

6.2. You have certain rights related to the processing of your personal data provided in the GDPR, including: Right  to information and free and open access to your personal data, as well as the right to request a copy of your personal data stored or otherwise processed by Pate Play; The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete; In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your personal data or the restriction of their processing, as well as to exercise your right to the portability of your personal  data (when applicable); Right to object, as well as rights related to automated decision-making – you have the right to object at any time, on grounds relating to your specific situation against the  processing of your personal data, including in the event that your personal data is used for profiling; If you have any doubts that your personal data is not being processed  lawfully by Pate Play, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Notice, or to seek the protection of your rights judicially.

6.3. Please note that Pate Play does not use your personal data for profiling or automated decision making.

6.4. The terms and conditions for exercising your rights related to the protection of personal data are regulated in detail in the GDPR and the Bulgarian Personal Data Protection Act. You may exercise your rights by making a written request to Pate Play on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Pate Play will provide you with full assistance in exercising the rights granted to you.

‍7. Data Protection Officer
‍If you wish to receive additional information on how Pate Play processes your personal data or you have questions related to the operation and application of the present Transparency Notice in the processing of personal data of employment applicants, you can contact ourPersonal Data Protection Officer at the following e-mail address: dpo@pateplay.com or by sending your questions to the registered address of theCompany, indicated at the beginning of this Notice.

‍8. Competent national supervisory authority for Personal Data Protection 
Commission for Personal Data Protection
‍Address: 2 Professor Tsvetan Lazarov Blvd., Sofia 159
E-mail: kzld@cpdp.bg Website: www.cpdp.bg 

‍9.Personal data processed in relation to whistleblowing
‍If you wish to find additional information on how Pate Play processes the personal data in relation to whistleblowing, please read the respective notice available on www.pateplay.com – “Whistleblowing”.

‍10.Changes to the present Privacy Notice
‍This DataProtection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website. 
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‍This Notice is effective as of 01.09.2023.